How Soon Hath Time! July 21 Deadline Looms For Investment Advisers But Grace May Be At Hand


The hasting days fly on with full career while the SEC proceeds with rulemaking to implement the Dodd-Frank Act’s changes to the regulation of investment advisers. Last week, Associate Director Robert E. Plaze in the SEC’s Division of Investment Management confirmed that the SEC intendes to complete required rulemaking by July 21, 2011 in this letter to David Massey, the President of the North American Securities Administrators Association, Inc. Transition problems, however, may result in some extensions of grace.

Mid-Sized Advisers

Pursuant to Section 410 of the Dodd-Frank Act, investment advisers with assets under management of between $25 million and $100 million will be required to withdraw from federal registration and register with one or more states. Howver, the Investment Adviser Registration Depository system (IARD) will need to be re-programmed. This may not be completed until year end. As a result, Associate Director Plaze wrote that the SEC “would consider” an extension to the first quarter of 2012 so that these mid-sized advisers “would have a grace period providing them with time to register with teh appropriate state regulators and to come into compliance with state law before withdrawing their Commission registration.”

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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